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Mutual Funds Legal Stuff

Mutual funds are offered by ING Direct Funds Limited, a wholly-owned subsidiary of ING Bank of Canada. ING Direct Funds Limited is a registered mutual fund dealer in Alberta, British Columbia, Saskatchewan, Manitoba, Ontario, Newfoundland, New Brunswick, Nova Scotia, and Prince Edward Island. This communication does not constitute an offer or solicitation by anyone in any jurisdiction in which such an offer or solicitation is not authorized or to any person to whom it is unlawful to make such an offer or solicitation.

Commissions, trailing commissions, management fees and expenses all may be associated with mutual fund investments. Please read the prospectus before investing. The indicated rates of return are the historical annual compounded total returns including changes in unit value and reinvestment of all distributions and does not take into account sales, redemption, distribution or optional charges or income taxes payable by any security holder that would have reduced returns. Mutual funds are not guaranteed, their values change frequently and past performance may not be repeated. There can be no assurances that any mutual fund will be able to maintain its net asset value per security at a constant amount or that the full amount of your investment in the fund will be returned to you.

Mutual funds are offered by ING Direct Funds Limited on a "no-load" basis. Management fees and operating expenses are paid by each Fund.

Mutual funds are not insured by the Canada Deposit Insurance Corporation or any other government deposit insurer, and are not guaranteed by ING Bank of Canada, or any other Canadian financial Institution.

ING Direct Funds Limited and ING Bank of Canada are not responsible for the content of any sites linked from or to this web site, and will not be held liable for any inaccuracies in the information not maintained by ING Direct Funds Limited or ING Bank of Canada.

Unclaimed Property

Unclaimed ING Direct Mutual Funds Accounts for residents of B.C., Quebec and Alberta

ING Direct Funds Limited is in possession of unclaimed property. Inquiries or claims respecting this property can be made in writing to:

ING Direct Funds Limited
Attn: Unclaimed Property
111 Gordon Baker Rd. Suite 110
Toronto, Ontario
M2H 3R1

Web Terms and Conditions

Except as otherwise agreed to by ING Bank of Canada ("ING DIRECT"), the following terms and conditions shall govern your use of the ING Direct Funds Limited Web Site.

Use of Information

The information contained in this Web site is not intended to provide specific legal, accounting, financial, or tax advice for any individual or entity and should not be relied upon in that regard.

Links to other web sites from this web site are for convenience only. ING DIRECT is not endorsing any third party products, services or information expressed or implied by content linked to this web site.

Accuracy and Changes

Rates of return provided by ING Direct Funds Limited on this Web site are believed to be accurate when placed on the Web site, however, posted rates are subject to change at any time without notice. To obtain our most up-to-date rates, please contact us by phoning us at 1-800-464-5678 or by email at funds@ingdirect.ca.

Direct Access

ING Direct Funds Limited may provide direct access to your account(s) by one or more of the following methods:

Electronic communications through this ING Direct Funds Limited Web Site;
Speaking over the telephone with an ING Direct Funds Limited Associate;
Other devices or equipment which ING Direct Funds Limited may designate for Direct Access.

Electronic Identification

Direct access to and use of the ING Direct Funds Limited Web site requires an electronic identifier which consists of the use of one or more of the following:

Client Number
Personal Identification Number (PIN)
Password
Or other security measures required by ING DIRECT.

You agree that electronic pages, such as ING Direct Funds Limited Web Site pages, accessed by Electronic Identification are written documents and that by electronically acknowledging by "clicking" any "buttons" stating "OK", "proceed", "continue", "approve" or "buttons" with similar intent shall have the same legal effect as if you had placed your signature by hand and provided hardcopy versions of such pages with intent to be legally bound with ING Direct Funds Limited or their content.

Your Liability

You agree that the use of the Electronic Identification is the legal equivalent to your written, signed instructions to ING Direct Funds Limited. You are bound by and liable for all use including unauthorized use of the Electronic Identification by other persons without your knowledge or consent.

ING Direct Funds Limited will be under no obligation to confirm the actual identity or authority of any user of the Electronic Identification or any component thereof.

You will not be responsible for unauthorized use of Electronic Identification occurring after notifying ING Direct Funds Limited in accordance with the notice provisions set out below.

Protection of Electronic Identification

You agree to keep Electronic Identification and all components thereof secret and safe to prevent unauthorized use. This includes but is not limited to:

memorizing and maintaining no record of any PIN, passwords or codes included in the Electronic Identification;
avoiding Code combinations which may be easy for someone else to guess or which are directly associated with you such as birth date, address, etc.;
avoiding selecting any part of another PIN, password or code;
take all necessary steps to ensure that any component of the Electronic Identification remains confidential to you - including keying in or speaking at a telephone or electronic device.

Notice to ING Direct Funds Limited

You must immediately phone ING Direct Funds Limited if any component of your Electronic Identification is lost, stolen, misused or may have become known to anyone other than you. You may contact ING Direct Funds Limited
Monday to Friday 8 a.m. - 8 p.m. (EST) at 1-877-464-5678.

Verification

ING Direct Funds Limited reserves the right to contact you to obtain confirmation of any electronic or telephone instruction before processing any transaction but will not be liable due to any inability or failure of ING Direct Funds Limited to contact you in order to confirm such instructions.

Recording Calls and Other Instructions

You agree that all telephone calls and other electronic correspondence may be recorded and kept as a record of your instructions.

Transactions and Limits

Transactions may be limited in dollar amounts or otherwise as ING Direct Funds Limited (or others) may determine and ING Direct Funds Limited (or others) can change these limits without notice to you.

Liability of ING Direct Funds Limited

ING Direct Funds Limited may cancel or restrict Direct Access or your Electronic Identification without notice to you. ING Direct Funds Limited will not be liable for any direct, indirect or consequential loss, damage or inconvenience arising directly or indirectly out of your use of, malfunction, cancellation, restriction or inability to access your account(s) at ING Direct Funds Limited by any means.

ING Direct Funds Limited and other ING entities, are not responsible in any manner for direct, indirect, special or consequential damages, howsoever caused, arising out of use of this Web site.

Unlawful behaviour
Do not use the ING Direct Funds Limited Web Site to communicate to others, to post on the ING Direct Funds Limited Web Site, or otherwise transmit to the ING Direct Funds Limited Web Site, any materials, information, or communication that either causes any harm to any person or that is illegal or otherwise unlawful, including without limitation any hateful, harassing, pornographic, obscene, profane, defamatory, libellous, threatening materials which constitutes or may encourage conduct that would be considered, a criminal offence, give rise to civil liability, promote the excessive, irresponsible or underage consumption of alcohol, or otherwise violate any law or regulation. Notwithstanding that ING Direct Funds Limited or other parties are involved in creating, producing or delivering the ING Direct Funds Limited Web Site, ING Direct Funds Limited shall have the right to monitor or review all communications, materials, transmissions, postings, discussions and chats. ING Direct Funds Limited and all parties involved in creating, producing or delivering the ING Direct Funds Limited Web Site, assume no responsibility or liability which may arise from the content thereof, including but not limited to claims for any of the above-noted matters.

If the ING Direct Funds Limited Web Site contains bulletin boards or any other message or communication facilities whatsoever (collectively, "Forums"), you agree to use the Forums only to send and receive messages and material that shall not, in any manner or to any extent, do any of the following:

commit any criminal or quasi-criminal offence, including without limitation, any pornography, hate, assault, or economic crime whatsoever;
defame, abuse, harass, stalk, threaten or otherwise violate the legal rights (such as rights of privacy and publicity) of others;
publish, post, distribute or disseminate any defamatory, infringing, obscene, indecent or unlawful material or information;
infringe, contravene, breach or otherwise interfere with or harm the rights of any other person, including without limitation any contractual, personality, confidentiality, privacy, moral, statutory, common law or intellectual property;
upload files that contain viruses, corrupted files, or any other similar software or programs that may damage the operation of another's computer;
delete any author attributions, trademarks, trade names, logos, legal notices or proprietary designations or labels in any file that is uploaded;
falsify the origin or source of software, information or other material contained in a file that is uploaded;
advertise or offer to sell any goods or services, or conduct or forward any surveys, contests, or chain letters; and,
download any file posted by another user of a Forum that you know, or reasonably should know, cannot be legally distributed in such manner.

You acknowledge and agree that all Forums are public and not private communications. Further, you acknowledge that chats, postings, conferences, and other communications by other users are not monitored, screened, sanctioned or endorsed by ING DIRECT, and such communications shall not be considered reviewed, screened, or approved by ING DIRECT. ING Direct Funds Limited reserves the right for any reason to remove at any time without notice any of the contents of the Forums received from users, including without limitation bulletin board postings. ING Direct Funds Limited reserves the right to deny, in its sole and absolute discretion, any user access to the ING Direct Funds Limited Web Site or any portion thereof without notice.

ING Direct Funds Limited Records

You accept any records or documents stored or produced by ING Direct Funds Limited through electronic means or device as sufficient evidence for all purposes to establish such documents and the contents as correct, authentic, and binding on you.

Ownership of Software, etc.

ING Direct Funds Limited (or a third party) owns any software or device ING Direct Funds Limited has supplied to you for purposes of facilitating ING Direct Funds Limited direct Access, and you use same under a non-exclusive, non-assignable license, solely for the purpose intended. ING Direct Funds Limited may demand their return at any time without prior notice and you will comply promptly, without keeping any copies.

Where Written Signatures are Required

Some ING Direct Funds Limited products may require your written signature and you will be advised when this is the case. You will be sent the terms and conditions and/or transaction verification which apply to the product or service which requires signature and will have five (5) business days from the date of giving of instructions by Direct Access to advise ING DIRECT if the material has not been received. If you do not so advise, you will be deemed to have received the terms and conditions and/or transaction verification.
Subject to the following paragraph, when you receive material requiring a signature you will sign it and return it to ING Direct Funds Limited. Your signature will signify your agreement to the purchase or renewal of the product or service in question and all terms and conditions relating to it.

Available Only Where Permitted by Law
The products and services described in the pages of Web sites of ING DIRECT Funds Limited and other ING entities, are only offered in jurisdictions where they may be legally offered for sale.

No confidentiality, use of information
The Internet is not a secure medium, and neither the privacy of your communications, nor visits to the ING Direct Funds Limited Web Site, can be guaranteed. The nature of Internet communications means that your communications may be susceptible to data corruption, unauthorized access, interception and delays. The ING Direct Funds Limited Web Site may include incomplete information, inaccuracies or typographical errors. ING DIRECT, and any other persons involved in the management of the ING Direct Funds Limited Web Site, may make changes in the information and content included in the ING Direct Funds Limited Web Site at any time without notice. ING Direct Funds Limited shall not be responsible for any detrimental reliance you may place on the ING Direct Funds Limited Web Site or its contents. Use of the ING Direct Funds Limited Web Site is on an "as is" basis and is strictly and entirely at your own risk. By entering the ING Direct Funds Limited Web Site you acknowledge and agree that any communication or material you transmit to the ING Direct Funds Limited Web Site, in any manner and for any reason, will not be treated as confidential or proprietary. Furthermore, you acknowledge and agree that any communications, information, ideas, concepts, techniques, procedures, methods, systems, designs, plans, charts, or other materials you transmit to the ING Direct Funds Limited Web Site may be used by ING Direct Funds Limited anywhere, anytime and for any reason whatsoever.

Hyperlinks
Although the ING Direct Funds Web Site may be linked to other sites, ING DIRECT is not, directly or indirectly, implying any approval, association, sponsorship, endorsement or affiliation with the linked site, unless specifically stated therein. By entering the ING Direct Funds Web Site you acknowledge and agree that ING DIRECT has not reviewed all sites linked to the ING Direct Funds Web Site and is not responsible for the content of any off-site pages or any other site linked to the ING Direct Funds Web Site. Your linking to any other off-site pages or other sites is at your own discretion and risk.

Applicable law
By entering the ING Direct Funds Web Site you acknowledge and agree that the ING Direct Funds Web Site will be construed and evaluated according to the laws of the Province of Ontario, Canada. You hereby agree and confirm that your use of the ING Direct Funds Web Site and all of the communications, transmissions and transactions associated with the ING Direct Funds Web Site shall have occurred in the Province of Ontario, Canada and that you submit to the exclusive jurisdiction of the courts of the Province of Ontario as the proper and most convenient forum concerning the ING Direct Funds Web Site. If you use the ING Direct Funds Web Site from another jurisdiction, you are responsible for compliance with any and all applicable local laws. ING DIRECT makes no representation that the materials contained within the ING Direct Funds Web Site are appropriate for customers outside of the Province of Ontario, Canada.

Changing These Terms

These Terms can be amended by notifying you by distributing ING Direct Funds statements, newsletters, or by posting on the ING Direct Funds Limited Web Site. You will be considered to have received notice of change, five (5) business days after ING DIRECT has mailed or sent to you, or ING Direct Funds Limited posting of notice. The effective date for changes contained in such notices will be the date stated in them, and if no date is stated, they will have immediate effect. Use of Direct Access after such time shall confirm your acceptance of and agreement to such amendments.

Copyrights belong to ING DIRECT
ING DIRECT is the registered copyright owner of the ING Direct Funds Web Site and no portion of the ING Direct Funds Web Site, including but not limited to the content, information, text, images, audio or video, may be used in any manner, or for any purpose, without ING DIRECT's prior written permission, except if indicated herein. Without in any way waiving any of the foregoing rights, you may download one copy of the material on the ING Direct Funds Web Site for your personal, non-commercial home use only, provided you do not delete obstruct, or change any copyright, trademark or other proprietary notices. Modification, repostment or use of the material on the ING Direct Funds Web Site in any other manner whatsoever and for any other purpose violates ING DIRECT's legal rights.

Trademarks Belonging to ING DIRECT or Other Entities

Certain names, graphics, logos, icons, designs, words, titles or phrases at this Web site may constitute trade names, trademarks or service marks of ING DIRECT or other entities. Trademarks may be registered in Canada and in other countries as applicable.

The display of trademarks on the pages of this Web site does not imply that a license of any kind has been granted unless expressly stated herein. Any unauthorized downloading, re-transmission or other copying or modification of trademarks and/or the contents herein may be a violation of federal or common law, trademark and/or copyright laws and could subject the copier to legal action.

®?* -- Netscape, Netscape Navigator, Netscape ONE, and the Netscape N and Ship's Wheel logos are registered trademarks of Netscape Communications Corporation in the United States and other countries.

®? -- Microsoft, Windows, Windows NT, MSN, The Microsoft Network and/or other Microsoft products are either trademarks or registered trademarks of Microsoft.

®** -- Apple, Mac, QuickTime and Macintosh are trademarks of Apple Computer, Inc.,
registered in the U.S. and other countries.

®!*-- Adobe, the Adobe logo, Acrobat, the Acrobat logo and Adobe Acrobat Reader are trade marks of Adobe Systems Incorporated.

®+ - RealNetworks, RealAudio, RealPlayer, WebActive, and the RN logo are registered trademarks of RealNetworks, Inc. RealVideo, RealMedia, the Real logo, the Daily Briefing logo, and Timecast are trademarks or service marks of RealNetworks, Inc.

®* - Trade mark of Interac Inc. ING Bank of Canada is an authorized user of the trade mark.
Unauthorized use of ING DIRECT's logos and/or name or trade names is prohibited. All information at this site is protected under the copyright laws of Canada and in other countries. In addition, certain information may be copyrighted by others. Unless otherwise specified, no one has permission to copy, redistribute, reproduce or republish in any form, any information found at this web site.

™ A registered trademark of ING Groep N.V. used under license by ING Bank of Canada.

General

The terms and conditions of other agreements relating to your other ING DIRECT business remain in force except as expressly altered by these Terms. If there is a conflict between any provision of those other agreements and these Terms, those Agreements prevail.